eNotes: Liability – February 2023 – Federal
February 01, 2023
SIGNIFICANT CASE SUMMARIES
FEDERAL CASE SUMMARY
Grady v. Rothwell
United States District Court for the Middle District of Pennsylvania
No. 4:22-CV-00428, 2022 U.S. Dist. LEXIS 203694
Decided: November 8, 2022
Conducting business nationwide is not enough to confer personal jurisdiction on an out-of-state furniture company for an accident occurring outside Pennsylvania.
Plaintiff, administrator of his fiancé’s estate, brought wrongful death and survival actions in the Middle District of Pennsylvania against Defendants Rothwell and La-Z-Boy Logistics for an automobile accident which killed Plaintiff’s fiancé. The accident occurred in Virginia. Plaintiff’s fiancé was in a minor car accident, incapacitating her car in the left hand lane where she then was struck again by a La-Z-Boy tractor trailer driven by Rothwell. The fiancé’s mother filed a similar Complaint in a Virginia court. The deceased’s mother and Defendants each moved to have fiancé Grady’s Complaint dismissed for their own reasons. The Court first examined Defendants’ Motion to dismiss for lack of jurisdiction.
The District Court ultimately granted Defendants’ Motion, dismissed the case, and then dismissed the deceased’s mother’s Motions as moot. The Court highlighted that Grady admitted that Rothwell does not live in Pennsylvania, and that La-Z-Boy is neither incorporated in nor keeps its principle place of business in the Commonwealth. Grady’s only allegation was that La-Z-Boy “conducts business . . . in . . . Pennsylvania.” He never alleged that La-Z-Boy has locations, employees, or other presence in Pennsylvania. The Court held that the mere fact a corporation does business within Pennsylvania is insufficient to establish general jurisdiction. Further, although Grady did not argue for specific personal jurisdiction over La-Z-Boy, the Court held that the case would not fall within the state’s long-arm statute.
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